Republic of the Philippines

REGIONAL TRIAL COURT

Iloilo City(Branch 6)
PEOPLE OF THE PHILIPPINES
75757
Threats
Plaintif,

CRIMINAL

CASE
For:

NO.
Grave

-versusAndrew Epal
Defendant.
x------------------------------------------x
MOTION TO DISMISS
Accused by the undersigned counsel and respectfully moves
to quash the information filed against him on the ground that the
court has no jurisdiction to try the present case.
ARGUMENTS
1. That the accused Andrew Epal is a minor.
2. The proper court to try the present case would be a Family Court.
3. The crime was committed Kalibo Aklan (Northern Iloilo) , hence,
the venue lies therein.
WHEREFORE,

it

is

respectfully

prayed

that

information filed against the accused be dismissed.

City of Iloilo, Philippines, January 31, 2015.

By: SGD
1

the

ATTY. Jethro Villaruel

Counsel for the Accused
4th Floor Mendel Building,
Mabini Dt, Iloilo City
IBP NO. 65643/ Jan. 2, 2013 / ILOILO CITY
PTR NO. 674774/Jan. 3, 2013/ ILOILO CITY
ATTORNEYS ROLL NO. 65342
MCLE COMPLIANCE NO. IV-0334183/03/20/154

Copy furnished:
NOTICE OF HEARING
ATTY. Jose Vencer
Counsel For Plaintif
Greetings:
Please take notice that the undersigned shall submit
the foregoing motion for the Court to resolve on February 14,
2015 at 3:00 oclock in the afternoon.
PROOF OF SERVICE
EXPLANATION (if by registered mail)